In Re Sarah O., 128 Conn. App. 323

Respondent mother appeals a judgment terminating her parental rights to her daughter Sarah O. in favor of the commissioner of children and families.
Sarah was adjudicated neglected and committed to the petitioner; the court found the mother failed to rehabilitate and to provide a safe, suitable home.
The department intervened after Sarah was removed due to an unsafe home environment and the mother's substance abuse and mental health issues.
Mother participated in various services (partial hospitalization, outpatient treatment, counseling, parenting programs) and maintained visits with Sarah, but housing and stability remained unresolved.
Trial found three main concerns: sobriety/relapse risk, mental health issues, and unsafe living conditions for Sarah.
The dispositional order concluded it was in Sarah’s best interest to terminate parental rights to provide stability and permanency.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether due process was violated by Herzner's posttrial position statement	Mother argues Herzner's posttrial statement was extrarecord evidence affecting the outcome.	Petitioner contends any error was harmless given the record and other evidence.	Harmless error; no manifest injustice.
Whether the department made reasonable efforts to reunify with Sarah	Mother claims insufficient efforts, including no individual treatment or housing help.	Department reasonably offered multiple services and referrals; mother failed to engage.	Not clearly erroneous; efforts were reasonable.
Whether the mother achieved a sufficient degree of rehabilitation	Mother benefited from services and progress, suggesting rehabilitation to care for Sarah.	Partial progress but not sufficient to enable timely parenting; housing and insight lacking.	Not clearly erroneous; rehabilitation insufficient.
Whether termination is in Sarah's best interests	Continuation of parental rights would better serve family reunification and stability.	Termination serves Sarah’s safety, stability, and permanency given past failures.	Not clearly erroneous; termination in best interests.

In re Tremaine C., 117 Conn. App. 521 (Conn. App. 2009) (Golding framework for unpreserved constitutional claims; plain error standard.)
In re Samantha C., 268 Conn. 614 (Conn. 2004) (Reasonable efforts standard; 'doing everything reasonable, not everything possible.')
In re Melody L., 290 Conn. 131 (Conn. 2009) (Rehabilitation standard allows considering factors beyond express court orders.)
In re Devon W., 124 Conn. App. 631 (Conn. App. 2010) (Defer to trial court on factual findings; clear and convincing standard.)
In re Janazia S., 112 Conn. App. 69 (Conn. App. 2009) (Best interests and permanency assessment in dispositional phase.)
Golding v. Perricone, 292 Conn. 187 (Conn. 2009) (Procedure for constitutional claims in noncriminal contexts.)